Patna High Court

Mandatory exhaustion of statutory remedies requires the appellate authority to dispose of pending appeals within a stipulated timeframe.

Vijay Kumar Ray vs The State of Bihar

Patna High CourtJUDGMENT: June 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a Public Distribution System (PDS) dealer holding License No. 116/2016 in Panchayat-Bardahiya, Saran, challenged the cancellation of his license vide Memo No. 2183 dated 18.12.2018 issued by the Sub-Divisional Officer, Marhaura

Source reference: p. 1-2

The petitioner sought a writ of certiorari to quash the cancellation order and a writ of mandamus to restore his license for distributing foodgrains and kerosene oil

Source reference: p. 2

During the proceedings, it was disclosed that the petitioner had already filed an statutory appeal (P.D.S. Appeal No. 03 of 2019) before the District Magistrate, which remained pending

Source reference: p. 3-4
02

Issues

1. Whether the writ petition is maintainable when an alternative statutory remedy of appeal is already being pursued by the petitioner

Source reference: p. 2-3

2. Whether the court should direct the appellate authority to expedite the disposal of the pending administrative appeal

Source reference: p. 4
03

Law Applied

Section 32(iii) [of the Bihar Targeted Public Distribution System (Control) Order, 2016] provides that any person aggrieved by the cancellation of a license may appeal to the District Officer within thirty days

Source reference: p. 2-3

Section 32(v) empowers the Appellate Authority to stay the operation of the impugned order

Source reference: p. 2-3

Section 32(vi) provides for a revision before the Divisional Commissioner if the appeal is not disposed of within sixty days or if the party is aggrieved by the appellate order

Source reference: p. 2-3
04

Reasoning

The court observed that the petitioner had already invoked the statutory remedy provided under the Control Order, 2016, by filing P.D.S. Appeal No. 03 of 2019 before the District Magistrate

Source reference: p. 3-4

The respondents argued that since the law prescribes a specific hierarchy for redressal—including appeal and revision—the petitioner must exhaust these remedies

Source reference: p. 2-3

Applying these rules to the facts, the court determined that rather than adjudicating on the merits of the license cancellation under Article 226, the appropriate course of action was to ensure the efficiency of the existing statutory process

Source reference: p. 4

Consequently, the court found it fit to mandate a time-bound disposal of the pending appeal to serve the interests of justice

Source reference: p. 4
05

Holding

The High Court declined to quash the cancellation order directly but disposed of the writ petition with a direction to the concerned authority (District Magistrate, Saran) to dispose of the petitioner’s pending appeal (P.D.S. Appeal No. 03 of 2019) within a period of three months from the date of receipt or production of the court's order

All pending interlocutory applications were also disposed of

Source reference: p. 4
Patna High Court

Original Court PDF

Vijay Kumar RayvsThe State of Bihar

Patna High Court · June 22, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment